Restriction of access to public registers for security reasons: key changes under Law No. 4576-IX

Yesterday, the Law of Ukraine No. 4576-IX of 21 August 2025, “On Amendments to the Civil Code of Ukraine and Certain Other Laws of Ukraine Regarding the Specifics of Providing Information from Public Electronic Registers Administered by the Ministry of Justice of Ukraine and Certain Other Public Electronic Registers” (“the Law”) entered into force.

The Law introduces a special procedure for providing information from certain public electronic registers for the period of martial law and for one year after it is lifted.

In particular, for this period, the Law provides that:

1. the registered address of legal entities engaged in the production, supply or provision of defence-related goods or services and other activities in the defence industry (“Defence Industry Entities”) may be deemed the address for official communications, including for receiving documents from state and municipal authorities. Defence Industry Entities are recommended to update the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Organisations (the “Unified Register”) accordingly within 60 days of the Law entering into force;
2. information on registered rights to real estate owned by any legal entities, when provided in electronic form, will, in the part relating to the location, include only data on state, the Autonomous Republic of Crimea and the region, and will not include the cadastral number of the land plot;
3. access to information from the State Register of Proprietary Rights to Immovable Property on real estate owned by legal entities will be restricted as determined by the Government;
4. upon an application by an authorised state body, and according to the procedure established by the Government, access may be restricted to information related to national security and defence contained in the following intellectual property registers:

• the State Register of Trademark Certificates of Ukraine;
• the State Register of Patents of Ukraine for Inventions;
• the State Register of Patents of Ukraine for Utility Models;
• the State Register of Patents of Ukraine for Industrial Designs;
• the State Register of Semiconductor Product Topographies of Ukraine;
• the State Register of Certificates of Registration of Copyright in Works; and
• the State Register of Contracts Relating to Copyright in Works.

Such information may be provided by the state organisation “Ukrainian National Office for Intellectual Property and Innovation” upon a written request from an authorised state or law-enforcement body designated by the Government.

Additionally, the Law requires the Ministry of Justice of Ukraine (the “Ministry”) to publish information from the Unified Register in the form of open data within two months from the date it enters into force.

Previously, access to open data from public registers administered by the Ministry was suspended pursuant to Order No. 1462/5 of the Ministry dated 13 April 2022. Subsequently, Order No. 423/5 of the Ministry dated 31 January 2023 partially restored access to such data, while maintaining restrictions for the Unified Register. The obligation to make the Unified Register data publicly available is now expressly set out in the Law, taking into account the newly introduced security-related restrictions.

Accordingly, the Law establishes a legal framework for strengthening the information security of data contained in public registers, in particular with respect to the protection of Defence Industry Entities. At the same time, certain restrictions (in particular those concerning the disclosure of location data for real estate owned by legal entities) will also affect a broader range of businesses.

In practice, however, the effect of the Law will largely depend on the Government, which must adopt the necessary secondary legislation within two months of the Law’s entry into force.

We hope that these amendments will strengthen both the information and physical security of Defence Industry Entities.

Additional notes

For further information on the topic please contact managing partner Mykola Stetsenko or senior partner Kostiantyn Likarchuk, or by telephone +380 44 591-3355 or via e-mail.